Government of Canada Defence and Security
Export Sales Organization
Process for Government to Government Acquisitions
Through the Canadian Commercial Corporation
PROPRIETARY INFORMATION
NOTICE RESTRICTIONS ON
USE AND DISCLOSURE
OF INFORMATION
This manual and communications concerning this manual developed by the Canadian Commercial
Corporation is the property of the Canadian Commercial Corporation. The manual and the information
contained therein is furnished with the understanding that it will not, without the prior written consent
of the Canadian Commercial Corporation, be used for any purposes other than in connection with the
evaluation of the Canadian Commercial Corporation and the selection of the procurement approach for
the project and in no event shall the manual or any information contained therein be disclosed to any
third party without the prior written consent of the Canadian Commercial Corporation.
CANADIAN COMMERCIAL CORPORATION
TABLE OF CONTENTS
Page
The Canadian Commercial Corporation
1
Introduction
1
Canada’s International Trade Portfolio
1
What Can Be Purchased
2
Key Canadian Defence Capabilities
2
Surplus Canadian Armed Forces Equipment
2
What Can Be Exported
3
Approvals Required
3
Export Controls
3
Automatic Firearms Country Control List
3
Other Releasability Issues (ITARS)
3
The Process for Government to Government Acquisitions From Canada
4
Step 1 - Buyer Makes Request to CCC
4
Step 2 - CCC Information Gathering
6
Step 3 – Integrity Compliance and Due Diligence on Canadian Supplier
7
Step 4 – Proposal Development and Contract Negotiation
8
Step 5 - Management of the Contract
9
The Benefits of Government to Government Acquisitions From Canada
10
The CCC Value Proposition
10
CCC Commitment to Ethical Business Practices
11
CCC Supplier Commitment to Ethical Business Practices
11
Contact
12
c
CANADIAN COMMERCIAL CORPORATION
THE CANADIAN COMMERCIAL CORPORATION
INTRODUCTION
As the world was rebuilding in 1946, Canada had the
means but not the mechanism to assist governments
of other nations in their efforts. The Government of
Canada responded with the creation of the Canadian
Commercial Corporation (CCC). This new organization
was formed to deliver the critical Canadian resources
desperately needed by European Governments for
reconstruction efforts and was designed to offer rapid
acquisitions to meet critical needs while maintaining
careful control over the significant public funds it was
managing for these purchases.
In 1956, CCC was given responsibility for Government of
Canada support of the Canada-US Defense Production
Sharing Agreement (DPSA). Under the DPSA, CCC acts
as prime contractor on almost all US Department of
Defense purchases from Canada.
CCC has evolved since that time but remains true to its
original commitment to provide governments around
the world with access to quality Canadian products and
services under its business lines of Global Defence and
Security and International Commercial Business.
CCC is a Crown corporation, a government-owned
enterprise, of the Government of Canada and is
governed by its enacting legislation, the 1946 Canadian
Commercial Corporation Act. The Act outlines CCC’s
broad mandate, which is to assist in the development
of trade by helping Canadian companies access
government procurement markets abroad and by
helping governments of other nations obtain products
(and services) from Canada through government to
government contracts.
The legislation also provides CCC with a range of
powers, including the ability to export products (and
services) from Canada either as principal or as agent
in such a manner and to such an extent as it deems
appropriate.
CCC is the export sales organization of the Government
of Canada that promotes acquisitions from Canada by
governments of the other nations through commercial
advocacy and government to government contracting.
For more information on the Canadian Commercial
Corporation Act visit:
http://laws-lois.justice.gc.ca/eng/acts/C-14/
CANADA’S INTERNATIONAL TRADE
PORTFOLIO
CCC reports to the Parliament of Canada through the
Minister of International Trade and annually tables in
Parliament a Corporate Plan and an Annual Report that
contains the results of implementing the Corporate
Plan. CCC, in conjunction with Foreign Affairs, Trade and
Development Canada (DFATD) and Export Development
Canada (EDC), forms the Government of Canada’s
International Trade Portfolio. The portfolio is structured
in such a way that all the portfolio organizations are
mandated with complimentary roles to ensure the
best results for Canadian companies doing business
internationally.
 DFATD provides diplomatic representation through 174 offices worldwide and undertakes economic diplomacy to support bilateral relations.
 EDC is the Government of Canada’s export credit agency and provides financing and insurance solutions to support trade.

CCC is the Government of Canada’s government to government contracting organization that provides a contracting mechanism for acquisitions from Canada.
Requests for CCC’s services can be made by
contacting CCC directly or by contacting
Embassies and Canadian High Commissions.
1
WHAT CAN BE PURCHASED
Any defence and security goods that are manufactured
in Canada or services provided in Canada and that are
available for export from Canada.
KEY CANADIAN DEFENCE CAPABILITIES
CCC provides simplified access to Canada’s world-class
defence and security technologies and expertise. The
defence and security solutions can be customized for
non-standard requirements delivered on a timely basis.
CCC can source supply in the following areas:
Air, Land, Sea Platforms

Armoured Vehicles & Survivability Systems

Special Mission Aircraft & Aircraft Missionization

Surface Combatant Ships

Joint Support & Off-Shore Patrol Ships

In-Service Support Solutions
Protecting the Soldier

Small Arms & Ammunition
 Chemical/Biological/Radiological/Nuclear Equipment & Soldier Systems

Medical Technologies

Human Systems Integrations
Command and Support

Command, Control & Communications Systems
 Intelligence, Surveillance & Reconnaissance Systems
Shelters
Training Systems

Interactive Maintenance Trainers

Live-fire Training & Weapon Systems

Close Combat Tactical Trainers
 Flight, Land & Naval Dynamic Synthetic Environments
2
Cyber-Security

Intrusion Protection Systems

Critical Infrastructure Protection Systems

Voice, Data, & Video Networking Solutions
For more information on assets available for purchase:
Contact the local Canadian Defence Attaché, or contact
CCC directly.
SURPLUS CANADIAN ARMED FORCES
EQUIPMENT
CCC can also sell surplus military equipment that is being
retired from use by the Canadian Armed Forces (CAF).
Purchases of CAF equipment “as is” can be made through
CCC or through the Department of Public Works and
Government Services Canada military surplus branch.
Should the equipment require upgrading or
refurbishment, CCC can arrange for a Canadian firm to
undertake the upgrade work as part of a government to
government contract.
CANADIAN COMMERCIAL CORPORATION
WHAT CAN BE EXPORTED
CCC can enter into a contract with most sovereign
governments and governmental organizations for
defence and security solutions. CCC can work with
all levels of government – national, subnational and
municipal. Some defence purchases will be subject
to Canada’s Department of Foreign Affairs, Trade and
Development Export Permit approvals , as detailed
below.
REQUEST APPROVALS REQUIRED
Some transactions require special approvals for CCC
participation.
Purchases Requiring Special Approvals:
1. Sales valued over $100M CDN require approval by
the CCC Board of Directors
2. Sales for the delivery of infrastructure projects
require approval by the Minister of International
Trade and Minister of Finance
3. Sales for the delivery of services over $2 billion CDN
in value, and 15+ years in duration require approval
of the Minister of International Trade and Minister
of Finance
EXPORT CONTROLS
Some products purchased through CCC will require an
Export Permit. Export controls give the Government
of Canada the power to control the export of goods
and technology from Canada. Responsibility for the
issuance of Export Permits lies with Export Controls
Division of the Department of Foreign Affairs, Trade
and Development. The Canadian supplier will make
the request to the Export Controls Division to grant the
Export Permit.
For further details, see the Military and Strategic Goods
and Technology section of the Export Control List:
http://www.international.gc.ca/controls-controles/
about-a_propos/expor/guide-2013.aspx?lang=eng
AUTOMATIC FIREARMS COUNTRY
CONTROL LIST
Some products purchased though CCC will additionally
require the buying country to be placed on Canada’s
Automatic Firearms Country Control List (AFCCL) as
an approved export destination. Certain prohibited
firearms, weapons, devices, or components thereof that
are included on the Export Control List may be exported
only to destinations on the Automatic Firearms Country
Control List and only to consignees that are government
or authorized by government.
Canada can place a country on the AFCCL when there is
an inter-governmental defence, research, development,
and production arrangement with a country such as a
Defence Cooperation Agreement or Defence Materiel
Cooperation Agreement.
For further details see the AFCCL approved country list at:
http://laws-lois.justice.gc.ca/eng/regulations/SOR-91-575/
FullText.html
OTHER RELEASABILITY ISSUES
In cases where a product or service is subject to the
International Traffic in Arms Regulations (ITAR) of the
United States, there will be a releasability review. The
releasability review process involves determining if the
technology involved is releasable by the US for export,
and is undertaken by the US DoD. If the sale involves a
system with technology that has not been previously
approved for export to the purchasing country, this
process will generally take longer than if the system
has previously been approved for export. The US DoD
reviews each proposed sale or transfer of defence items
or services and then provides a recommendation to
the US Department of State, which then informs the
applicant of its decision. The Department of State has
the final authority for ITARS restricted material. The
length of the review process is difficult to estimate due
to many variables.
3
THE PROCESS FOR GOVERNMENT TO GOVERNMENT
ACQUISITIONS FROM CANADA
CCC is the Government of Canada’s defence and security export sales organization. CCC has the mandate to
support foreign government acquisitions from Canada through government to government contracts backed by a
Government of Canada guarantee of contract performance.
Step
1
BUYER MAKES REQUEST TO CCC
Requirement Determination
and Procurement Strategy
Buyer
Establishes
Project Lead
Buyer
Determines
Requirements
Buyer
Requests
CCC G to G
Briefing
Determine Request Type
Request for a
Competitive
Proposal
Request
for an
Unsolicited
Proposal
Requirement Definition and Procurement Strategy
While the purchasing government is in the requirement
definition stage and is considering which procurement
strategy will yield the most effective approach, the
project lead may request a meeting with CCC to better
understand the option of working with Canada for a
government to government acquisition. CCC can provide
a briefing to explain Canada’s foreign military sales
program for acquisitions from Canada.
To request a briefing from CCC, contact the
local Canadian Embassy or High Commission
Trade representative. They will coordinate a
meeting or call based on the buyer’s needs.
Determine Request Type
The buyer determines the type of request as pricing and
availability (P&A), competitive proposal or unsolicited
proposal. A response to a request for pricing and
availability data will be strictly for planning purposes,
and is not intended as an offer for sale. A request for
either a competitive or unsolicited proposal may result
in CCC providing an offer to sell defence and security
products and services, depending upon the nature and
4
Request for
Pricing and
Availability
Data
Send Request to CCC
To CCC
through the
Canadian
Embassy
Directly to
CCC
availability of the specific defence and security products/
services being requested.
Please identify any international competitions/
solicitations related to the purchase, if any. CCC can
respond to an international solicitation for defence
equipment or services with a competitive proposal. If
the purchasing country has issued an international
solicitation, request for information (RFI), or request for
proposal (RFP), note this detail in the request and include
copies of any documents so that the response meets all
of the requirements specified in the solicitation, RFI, or
RFP.
CCC may not enter into or commit Canadian firms to any
offset agreement. Responsibility for negotiating offset
arrangements and satisfying all related commitments
resides with the Canadian firm involved. CCC will not
include offset arrangements in the proposal. However,
the Canadian contractor may request offset costs be
included as part of the line item(s) unit cost in P&A data
and in the estimated prices quoted in a proposal.
Provide Details For Request
 Specify who and what organization is making the request (Army, Navy, Air Force, or other agency). Include as much detail as possible, including: CANADIAN COMMERCIAL CORPORATION
full name, phone number, mailing address, and email address.

Describe the type of equipment desired, including as much detail as possible. Identify the preferred Canadian supplier, or describe the operational requirement for the request and CCC can offer a list of Canadian suppliers.
 Indicate the request type as competitive proposal, unsolicited proposal, or pricing and availability data. Identify any international competitions that may be related to the purchase.
 If required, indicate any additional facilities (or modification to existing facilities) to house, support, and maintain the new equipment.

Provide the budget amount for the request, and the source of funding for the project. If required as part of the budgeting and approval process, indicate in the maximum initial deposit and appropriate timing for the payment.
Send Request to CCC
A request may be sent directly to CCC by contacting the
CCC Regional Director. Alternatively, the request can be
sent to the Canadian Embassy or High Commission.
Please refer to the Contact Information section.
5
Step
2
CCC INFORMATION GATHERING
Exploratory Meeting between
CCC and Buyer
CCC Response to Request
CCC
Acknowledges
Request
CCC
Confirms
the Request
Type
CCC Confirms
Supply
Available from
Canada
Presentation
of CCC’s G to
G Contracting
Approach
CCC Response To Request
CCC acknowledges the expression of interest from the
buyer with a timeframe for a full response. CCC will
confirm whether the buyer is expecting pricing and
availability data for budgeting purposes or a competitive
or unsolicited proposal as the basis for a contract.
CCC will inform the buyer immediately if CCC is unable
to provide a solution or required information. If supply is
available from Canada, CCC will engage with the buyer’s
preferred Canadian supplier or suggest options for the
buyer’s selection.
The Exploratory Meeting
CCC works with the buyer and supplier to establish
the framework for the transaction, including the
agreement on use of commercial contracting approach
or foreign government procurement regulations, and
use of Canadian, domestic or third country arbitration
proceedings.
CCC works with the buyer and supplier to explore the
risk mitigation mechanisms that will allow the buyer
to mitigate any perceived risk in the most economical
manner for the project, such as the use of advance and
progress payments, financial security and insurance
requirements.
6
Suitability of
CCC’s G to G
Contracting
Approach
for this
Acquisition
Risk Mitigation
Mechanisms
Determine
Requirement
for an MOU
When a government seeks to collaborate
with Canada, CCC can become involved and
elevate the collaboration to a government
to government engagement through a
Memorandum of Understanding.
MOU Drafting and Signature (Optional)
Where the buyer needs a Memorandum of
Understanding (MOU) as a policy instrument, the MOU
would outline a mutual commitment to explore how
our two sovereign nations could work together on
procurements. The MOU allows CCC and the buyer
to explore how CCC’s government to government
mechanism for directed contracting can facilitate
acquisitions from Canada. This non-binding arrangement
addresses how CCC and the buyer would work together
for purchases. If mutually agreed, a signing ceremony
can be arranged to commemorate the event.
CANADIAN COMMERCIAL CORPORATION
Step
3
INTEGRITY COMPLIANCE AND DUE DILIGENCE ON CANADIAN SUPPLIER
Supplier Integrity
Due Diligence
Questionnaire
Enhanced
Managerial
Review
Requirement Clarification
Non-Technical
Review and
Assessment of
Requirement
CCC has a proven due-diligence process and knowledge
of Canadian suppliers. Prior to contracting with a
Canadian supplier, CCC assures itself that the Canadian
supplier proposed to undertake the work for the buyer
has the capability to deliver the project.
Integrity Compliance Due Diligence Questionnaire and
Certificate of Compliance
The supplier must complete a mandatory Due
Diligence Questionnaire, which requests information
on supplier business ethics and use of agents or other
representatives. CCC requires the supplier to sign a
certificate of compliance for the information provided.
If CCC believes further due diligence on the integrity
of the supplier is required, a full Enhanced Managerial
Review is undertaken. CCC will assess whether a
company has taken appropriate measures to prevent
bribery and corruption by assessing whether the
supplier’s programs, processes and systems are
designed to reduce the likelihood of illegal or unethical
acts from occurring.
Project Requirement Clarification
At this step, CCC has a Canadian supplier with which
it can engage with the buyer to clarify the project
requirements. CCC works with the buyer to scope
the project to be delivered and to clarify expectations
around the project. CCC undertakes a non-technical,
common sense review and assessment of the
requirement to ensure that CCC and the supplier are
clear about the requirement for proposal development.
CCC and supplier identify any information gaps that
need to be filled, such as potential operating challenges
Identify
Information
Gaps to be
Filled
Supplier Capability
Technical
Assessment
Managerial
Assessment
Financial
Assessment
and product life cycle issues if harsh conditions exist
locally, or detailed specifications that the buyer may
have developed for sophisticated pieces of equipment.
Technical/Managerial/Financial Due Diligence of
Canadian Supplier
Once clarity is achieved on the requirement, the
Canadian supplier must also provide CCC with
information on its technical, managerial and financial
capability to deliver on the proposed project.
In its technical due diligence, CCC will establish that 1)
the technical expertise of the supplier is sufficient to
meet the requirements of the project, 2) the supplier
has the capacity to undertake the project, and 3)
the risk of the product or service not being available
through alternate sources has been analyzed. CCC may
undertake site visits to supplier locations, as required.
In its managerial due diligence, CCC will establish that
1) the supplier has a management team capable of
carrying on the business of the firm during the life of
the CCC contract; 2) the supplier has a project team
capable of managing the project; and, 3) the supplier
has previously managed successful export contracts in
markets with similar risk profiles to that of the proposed
project.
In its financial due diligence, CCC will establish that 1. the risk of supplier insolvency during the contract period is mitigated;
2. the supplier’s cash-flow capacity is adequate to
meet the project’s cash-flow demands; and,
3. the supplier can withstand cost overruns
commensurate with the risk of the project.
7
Step
4
PROPOSAL DEVELOPMENT AND CONTRACT NEGOTIATION
Proposal and Letter of Support
Supplier and
CCC Prepare
Proposal
CCC Prepares
Letter of
Support for
the Proposal
Proceeding to Contract
Authoring
and
Negotiation
of the
Contract
Contract
Signing
Supplier and CCC Prepare Proposal
Proceeding to Contract
The supplier will either prepare pricing and availability
data, an unsolicited proposal, or a competitive proposal
based on the request received from the buyer. The
degree of detail contained in the proposal will be
determined by the type of proposal required.
CCC works together with the buyer and the supplier to
assist in the structuring of the contract to reflect the final
technical proposal and the results of discussions around
cost, scheduling and financing for the project and
such commercial terms and conditions as are mutually
acceptable to all parties. Finally, CCC will explore the
buyer’s need for payment to be held in trust with CCC
and will seek a waiver of bonding requirements by the
buyer given the Government of Canada/CCC contractual
commitment of contract performance.
A price and availability proposal will contain a rough
estimate of numbers for budget planning, and will
contain significantly less detail than a proposal.
Unsolicited and competitive proposals include a
technical proposal and financial proposal for buyer
consideration. The supplier will require access to the
buyer to clarify any questions on the requirements as the
proposal is being developed. CCC reviews the proposal
and drafts the contractual language for the offer.
CCC may also issue to the buyer a Letter of Support,
which may be conditional or unqualified depending
upon the extent and status of the due diligence of the
supplier and the project that CCC has undertaken at that
time. This letter indicates to the buyer that CCC would
be willing to participate in the arrangement, as a prime
contractor to the buyer, depending on the negotiation of
a mutually acceptable contract and depending upon the
satisfaction of the conditions.
8
Contract Signing
If mutually agreed, a signing ceremony can be arranged
to commemorate the event. With the consent of the
buyer, a news release will be issued from the Office of the
Canadian Minister of International Trade.
Concurrent Domestic Contract Negotiation
CCC negotiates any terms and conditions necessary to
put the domestic contract in place with the Canadian
supplier. The buyer’s unabridged contract with CCC
forms the basis of the domestic contract with the
supplier. CCC prepares and arranges documents
regarding supplier’s guarantees, parental guarantees,
security deposits, insurances etc. CCC notifies the buyer
that the domestic contract is in place.
CANADIAN COMMERCIAL CORPORATION
Step
5
MANAGEMENT OF THE CONTRACT
Post Project
Contract Management
Contract
Management
Planning
Progess
Reporting
Completion of
Contractor
Effort
Completion of Contract Effort
CCC ensures supplier performance requirements are
completed per the terms of the contract. CCC manages
warranty obligations per the terms of contract. The
buyer has direct access to the supplier for resolution of
technical issues. CCC engages should the solution to the
technical issue require a contract amendment.
Financial Close
Out
Review Future
Opportunities
deliveries in accordance with the Contract and the Contract Management Plan.
 Conducting/attending Progress Review Meetings, as required.
 Applying the process identified in the contract for resolution of technical or administrative problems, as required.
Contract Amendments
Financial Administration
CCC manages any Canadian supplier re-certifications
and new approvals for amendments to contracts. All
changes are negotiated by CCC and documented in the
contract terms. All contract amendments become part
of the contract which is managed by CCC. CCC performs
administration of contract terminations.
CCC is responsible for the financial administration of the
contract. This responsibility includes management of
financial securities, funds advanced by the buyer, as well
as payment for approved progress claims and invoices.
Contract Management Planning
All funds from the buyer flow through CCC to the
Canadian supplier. CCC establishes a contract
management team and develops the Post-Contract
Management Plan for the project. The contract
management team is responsible for:
 Monitoring supplier performance of the contract.
 Overseeing implementation of contract terms that are required immediately after award .
CCC issues progress reports for project and financial
activities related to the contracts as per the contract.
These progress reports may include Contract Reports,
which detail the status of the project in terms of
expenditures and deliveries, and Statement of Account
Reports.
Financial Close Out
CCC resolves any outstanding payables/receivables and
resolution of contract balance. Any unused portion of
the advance is returned to the buyer upon contract close
out.
 Performing post-award liaison with the supplier and buyer.

Monitoring supplier performance leading to 9
THE BENEFITS OF GOVERNMENT TO GOVERNMENT
ACQUISITIONS FROM CANADA
The CCC approach has a special quality that significantly
reduces the commercial risk for a purchasing
government. The risks reduced are those that would
normally be associated with an open call for proposals,
including the confidential nature of certain defence and
security acquisitions, the investment in substantial upfront tender preparation costs, and the commercial risk
and potential delay of the award of a contract to an, as
yet, unidentified party.
Most nations’ procurement laws and regulations include
exceptions for urgent acquisitions and for acquisitions
for national security purposes – which will allow the
use of government to government arrangements.
If a government has used the Foreign Military Sales
option offered by the United States Department of
Defense, then the purchasing government may have
used this exception to acquire products or services on a
government to government basis.
Aside from the avoidance of extensive tender costs and
time delays, there are many elements inherent in the
CCC approach which provides value across a balanced
scorecard of success factors.
THE CANADIAN PACKAGE
CCC works closely with Canada’s Department of National
Defence (DND) and the Canadian Armed Forces (CAF) to
meet the needs of purchasing governments, while also
supporting Canada’s defence relationship with its allies
and partners.
Under the coordination of the Materiel Group’s Director
General International and Industry Programs, DND/CAF
support is available for Canadian defence materiel sales
where unique military capabilities or defence expertise is
required, subject to operational priorities.
Aside from the avoidance of extensive
tender costs and time delays, there are
many elements inherent in the CCC
approach which provides value across a
balanced scorecard of success factors.
CCC VALUE PROPOSITION
Fast and Simple
Reduced Acquisition Risk
 Expedited acquisition process on a government to government basis with CCC

 Access to any technology or expertise commercially available and approved for export from Canada
 Customized solutions to defence and security needs for non-standard requirements delivered on a timely basis
Enhanced Bilateral Relationship
 Reinforcement of political, economic and security relationship

CCC, as Prime Contractor, brings the Government of Canada’s support to the acquisition from identification of the Canadian supplier to the end of the warranty period
 CCC can hold the purchasing government’s advance payments in trust until contract execution
10
Government of Canada assurance that the contract will be performed according to the agreed terms and conditions that often results in the elimination of costs associated with bonding
 Due diligence conducted by CCC on Canadian supplier’s technical, financial and managerial capability to satisfy CCC of the supplier’s ethical business practices and ability to deliver on the contract

Purchasing government has direct access to Canadian supplier during contract execution for technical issues arising through the length of the contract
 Mitigation of project risks and assurance of ethical business practices with CCC contract monitoring throughout the length of the contract
CANADIAN COMMERCIAL CORPORATION
CCC COMMITMENT TO ETHICAL BUSINESS
PRACTICES
CCC ACCOUNTABILITY TO PARLIAMENT AND ITS OTHER
STAKEHOLDERS
CCC, as a Crown corporation of the Government of
Canada, is accountable to numerous stakeholders
including its Shareholder-the Government of Canada,
customers, employees and the larger domestic and
international community.
The Office of the Auditor General of Canada conducts
annual financial audits of CCC’s financial statements as
well as periodic special examinations of the Corporation
and its performance. The Office of the Auditor General
of Canada provides the Parliament of Canada with
independent information, advice, and assurance
regarding CCC’s business practices and stewardship of
public funds.
CCC must conduct its business in a transparent manner
by filing a summary of its Corporate Plan and an Annual
Report with the Parliament of Canada each year,
through the Minister of International Trade. Further, the
Financial Administration Act requires that CCC prepare
and make public quarterly financial reports within 60
days after the end of CCC’s fiscal quarter.
PRUDENT MANAGEMENT OF RISK
CCC has established a comprehensive Enterprise Risk
Management (ERM) Program for the management of
risks. This Program identifies the strategic, operational
and transactional risks facing CCC. It also sets out
the processes for their management in the areas of
risk identification, assessment, response, control,
monitoring, reporting, and communication. The Board
of Directors annually reviews the ERM Program and
assesses whether or not changes are needed.
CODE OF CONDUCT AND BUSINESS ETHICS
CCC views business ethics as fundamental to successful
business practices. Operating ethically means, at a
minimum, conducting its affairs in accordance with the
letter and spirit of the applicable laws of the countries
in which CCC does business and complying with the
Canadian Corruption of Foreign Public Officials Act.
In addition, CCC requires its employees to conduct
business with honesty, integrity and fairness. CCC’s Code
of Conduct and Business Ethics defines the Corporation’s
commitment to ethical conduct, the environment
and human rights. It also spells out the policies and
procedures that govern the behaviour of employees
of the Corporation including conflict of interest. All
employees sign an annual statement confirming they
are in compliance with the requirements set out in this
Code.
CCC SUPPLIER COMMITMENT TO ETHICAL
BUSINESS PRACTICES
INTEGRITY COMPLIANCE
CCC is committed to fulfilling its mandate with a high
standard of integrity. CCC requires the same level of
commitment to personal integrity from all persons with
whom the Corporation conducts business. CCC has a
mandatory requirement that its Canadian suppliers
complete a Due Diligence Questionnaire revealing any
and all criminal convictions of the company and its
principals for which a pardon has not been granted.
Where CCC is aware that the supplier (or any of its
principals or related companies) is under investigation
(or has been convicted of, or charged with an offence)
under the Corruption of Public Foreign Officials Act,
(or any other similar legislation which involves illegal
business practices, whether in Canada or elsewhere),
CCC is required to complete an Enhanced Managerial
Review of the company to determine whether
the company has demonstrated that it has taken
appropriate measures to prevent further offences from
being committed.
CONTRACTUAL LANGUAGE
All CCC domestic contracts with Canadian suppliers
include language dealing with corruption and bribery
and international sanctions. This language creates
affirmative obligations on the Canadian supplier to
behave in a manner consistent with the expectations
of the Government of Canada. CCC Prime Contracts are
typically based on international contracting standards.
MONITORING
The manner and extent of monitoring will depend
on the nature, extent (both duration and value) and
location of the project covered by the Prime and
Domestic Contracts. In some instances, it may be
appropriate to require periodic compliance reports
by the Supplier and, possibly, verification by CCC
compliance personnel or a third party (counsel,
accountant, or consultant) of the source information
that the reports are based on.
11
CONCLUSION
There are many benefits to exploring a government to
government contracting approach with the Government
of Canada. CCC appreciates the opportunity to engage
with senior officials of the purchasing government to
discuss how a government to government approach
with Canada might make plans a reality.
CONTACT CCC TODAY
For further information or to discuss a priority
acquisition, please contact:
CANADIAN COMMERCIAL CORPORATION
50 O’Connor Street, 11th Floor
Ottawa, Ontario K1A 0S6
T: 1-613-996-0034
E: [email protected]
DEPARTMENT OF FOREIGN AFFAIRS, TRADE
AND DEVELOPMENT
125 Sussex Drive
Ottawa, Ontario K1A 0G2
12
CANADIAN COMMERCIAL CORPORATION
50 O’Connor Street, 11th Floor
Ottawa, Ontario K1A 0S6
T: +1.613.996.0034 | F: +1.613.995.2121
Toll free in Canada : 1.800.748.8191
www.ccc.ca
© 2015 Canadian Commercial Corporation. All rights reserved.
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